U.S. Political Contributions

Update 1/22/21The volunteer employee board of the Whirlpool Political Action Committee (WCPAC) has decided to pause all contributions to political candidates and all employee contributions to the PAC. The WCPAC has always had a focus on supporting candidates who help create a positive manufacturing environment in support of our 15,000 manufacturing employees at our 9 U.S. factories, especially given that of the products we make, over 80% of what we sell in this country is assembled in this country.

Whirlpool Corporation believes that active participation and engagement in the public policy arena is an important part of being a responsible corporate citizen, vital to the democratic process, and important to our company’s success. We are committed to engaging in a dialogue with policy makers on a wide range of public policy issues important to our company and within communities where we operate, including trade, taxes, energy, environment, climate, privacy, affordable housing, and intellectual property. Our business is subject to legislative and regulatory requirements at the federal, state, and local levels and changes to rules can have a significant impact on our shareholders, customers, employees, and communities.

Whirlpool Corporation Political Action Committee (WCPAC)

Our government relations team represents Whirlpool Corporation on important policy issues before Congress, the Administration, regulators, and state and local governments across the United States. In addition to our company’s advocacy efforts, Whirlpool Corporation participates in the political process through the Whirlpool Corporation Political Action Committee (WCPAC).

Established in 1976, WCPAC is a voluntary federal political action committee. WCPAC is the authorized means for Whirlpool Corporation employees, who are U.S. citizens or green card holders, to pool personal, voluntary financial donations to make political contributions to candidates seeking elective office at the federal and state level.

WCPAC makes monetary contributions to state and federal political campaigns and other political action committees. WCPAC’s board consists of 10 employees from a variety of Whirlpool Corporation business units. The board votes on a quarterly and ad-hoc basis in determining the recipients of the WCPAC fund. Among other factors, WCPAC has historically based its political giving based on the following criteria: pro-business philosophy, a favorable voting record or position on key issues of importance to Whirlpool Corporation, constituent relationship with Whirlpool Corporation, campaign finance need, chances of winning and closeness of race, and committee affiliation. WCPAC focuses on candidates that promote a positive manufacturing environment to best enable us to operate our 9 US factories and support our employees in a highly competitive global economy.

WCPAC is regulated by the Federal Election Commission (FEC). WCPAC files regular reports with the FEC and relevant state election commissions on its receipts and disbursements. Reports filed with the FEC and a complete list of WCPAC political contributions are available to the public at www.fec.gov.

Trade and Professional Associations

Whirlpool belongs to a number of trade and professional associations at the national, state, and local level. Our company’s position on public policy issues are often communicated through these organizations, which enables us to reach government officials more efficiently and in cohesion with industry partners. We do not always agree with the positions taken by these trade associations and we regularly communicate our specific position on a wide range of issues and policies.

For income tax purposes, Whirlpool receives information from trade associations and tax-exempt organizations regarding the amount of our funds that are used for lobbying expenses and political expenditures according to IRS statutes. The following associations notified us that they spent either (a) $25,000 or more of the dues we paid; or (b) 10% or more of the dues we paid, on nondeductible lobbying or political expenditures:

Trade Associations

Percentage of Dues Used for Lobbying/Political Expenditures

Association of Home Appliance Manufacturers (AHAM)

Council on State Taxation (COST)

Iowa Association of Business and Industry

National Association of Manufacturers (NAM)

National Association of Home Builders (NAHB)

19.6%
50%
25%
20%
19%

Compliance

Whirlpool maintains comprehensive compliance procedures to ensure that its activities are conducted in accordance with all relevant laws governing political contributions and lobbying activities. Additionally, as part of its oversight role, the Board of Directors annually reviews the company’s Code of Ethics, which addresses the company’s policies and practices related to political contributions. Whirlpool Corporation quarterly files reports with the Secretary of the U.S. Senate and the Clerk of the U.S. House of Representatives detailing its lobbying activities. Copies of these filings are available at www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm.